RMI Nuclear Justice Documents

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Comments on Appendix II;

"Basic Considerations

in the Assessment of the Cancer Risks and Standards

for Internal Emitters" by Edward A. Martell*

Page 2, lines 9-13 -"Bair et al. (10) £311 to take into account the
full implications of some of the recent published results:
in particular,
the observed higher tumor risks for 38pu09 than for
Pud9 (11)
the
apparently limited biological response of mammal lung cells from 38pu
and

Pu incorporated into ceramic microspheres

Comments:

12,

vee!

It is highly unlikely that Dr. Bair would fail to take

into account the implications of data emanating from his own Laboratory (11)**;

similarly, it is not realistic to assume that Dr. Richmond would fail to
appreciate data from his own experimental work.
Page 2, lines 13-17 - "...and the tobacco smoke radioactivity results (14) ,
The latter results imply that as little as a few picocuries of insoluble
alpha emitting particles in the lung may give rise to a significant risk
of lung cancer and other serious health effects in the chronic exposure case."
Comments:

The Public Health statistics correlating tobacco smoking

and incidence of lung cancer and other diseases do not distinguish selectively
between the alpha emitters and the rest of the tobacco smoke as causative
agents,

Extensive epidemiological observations suggest that the etiology

of lung cancer in smokers is different from that in irradiated populations.
The excess risk of lung cancer produced by radiation persists for at least
three decades after single or briefly fractionated exposures; it does not

show any appreciable return toward normal levels for twenty years following
-

+

an initial 8-12 year latency.

On the other hand, when smoking is continued

for a prolonged period and then terminated, excess risk remains constant

for only 1-3 years after which a steady decline to normal occurs in 10-14
years.

The striking difference in the temporal pattern of excess mortality

* The author referred to herein is Dr. Martell.
**Numbers throughout are to Dr. Martell's references.